The Finance Bill and its accompanying notes run to more than 800 pages with 152 clauses leading tax experts to express fear that the 'devil will be in the detail' of the Bill which will be a 'frightening' prospect to read.
Disappointment in the profession over changes to double tax relief and controlled foreign was set to continue however as the Bill continued with reform sannounced in the Budget.
The English ICA and the 100 Group of Finance Directors have both written to the Treasury demanding the changes not go ahead, but signals from the Finance Bill indicate the government is determined to forge ahead despite criticism from industry and the profession.
Frank Haskew of the English ICA’s Tax Faculty said: ‘There’s a lot still to play for and the devil will be in the detail of the schedules.’
The Bill itself numbers 285 pages, but the schedules containing the detailed notes on each clause cover 558 pages.
Haskew said: ‘We were expecting a bill of 500 pages. However this is certainly a record breaking Bill in terms of size even it isn’t in terms of clauses.’
The Treasury’s inclusion of the reforms to DTR and CFC’s will be a disappointment and will add to the feeling among campaigners that they are fighting an uphill battle to stop the reform.
But despite the Bill determination remains to fight on.John Coombe, chairman of the 100 Group of Finance Directors, maintains that the changes are unfair and need to be stopped because they would make the UK unattractive for multinational firms.
Changes to DTR would remove the use of so-called offshore mixer companies. Currently mixers are used to offset income paid in high tax countries against income from low tax countries. Averaging out the tax rates offshore allows multinationals to avoid having to pay top-up tax when the money is remitted to the UK.
Coombe said: ‘The mixers have been used by British companies for many years and they fulfil a very simple task. Removing mixers may be counter productive because companies that can will keep money off-shore and when they make investments they will make them offshore.’
He added: ‘Everyone who pays tax and has foreign income is opposed to this.’
English ICA asks chancellor to dump double tax changes from Finance Bill